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Home My WebLink About95-01032 ~ J ., j ~ ~ p J - I 1 I , .: .,' , . ~" . ,"" ...<'::'~'~'. .,-.:- ..,,:~~~,. ..~- 0'" '.;:. . " " ". .~ " ",.'" ",",.' f.'- '. ;T: ~ .I;"~~ ~~'" ..!.l'';'" . .~.~':q;.b7~it.:-~:-;:;.~-:'- , )0 ~,'.r"'+- "J:"",,t":!{"'- , .. ,'. ,.;,'.;-',-....\ -.",.,,". '-- ,. . . j . ~ -, ,. .. -' ":. "'",:' " ',,\: HAlf 3 3 III PH 'SS I) rl' tD Jffl01' F TH" ""nr · GUHB(I~"" HO/jOlA~t P!'u'--'-,f) ON'IIlY ,nNSYt'/PI" , '. 3:3 .9$ t1~ ~/~ fJ.~~ 3- 3.ff" ~;Z; /I-~? dft' '3:3 .95- ~ ~ ?; ..y".,.a.-& Theresa Barrett Male Supreme Court #46439 10 South Market Square Suite SOD Harrisburg. PA 17101 (717) 233-3220 Attorney For Plaintiff AMY K. KOKOS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Civil Term 1995 W. ROGER BOWMAN Defendant CIVIL ACTION - CUSTODY COMPL~INT POR CUSTODY 1. Plaintiff, Amy K. Kokos, currently resides at 112 Wyncote court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, W. Roger Bowman, currently resides at 5960 89th Avenue North, Pinellas Park, Pinellas County, Florida 34777. 3. Plaintiff seeks custody of the following child: bM Present Residence Date of Birth Brandy Marie Bowman 9/17/87 112 Wyncote ct. Mechanicsburg, PA The child was not born out of wedlock. The child presently is in the custody of Plaintiff, who resides at 112 Wyncote Court, Mechanicsburg, Pennsylvania. During the past five (5) years, the child has resided with the fOllowing persons at the following addresses: bM Address ~ 8/93 to Present Amy Kokos Dean Kokos 112 Wyncote ct. Mechanicsburg, PA Amy L. Bowman (Rokos) Old Trail Road Etters, PA 1989 - 8/93 The mother of the child is Amy L. Rokos, currently residing at 112 wyncote Court, Mechanicsburg, PA 17055. She is married. The father of the child is W. Roger Bowman, currently residing at 5960 89th Avenue North, Pinellas Park, Florida 34777. He is single. 4. The relationship of Plaintiff to the child is that of The plaintiff currently resides with the following mother. persons: her husband, Dean Rokos, and the subject child. 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with the following persons: his parents. 6. plaintiff has participated as a party in litigation concerning the custody of the child in the parties' uncontested divorce action which was filed in the circuit court, Fifth Judicial circuit, in and for Hernando County, Florida and docketed to case number 89-1103-CA-01. A true and correct copy of the Final Judgment Dissolving Marriage, with the property settlement agreement, is attached as Exhibit "A". Plaintiff has no information of a custody proceeding concern- ing the child pending in a court of this Commonwealth. 2 Plaintiff does not know of any person not a party to this proceeding who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because, since the parties executed the settlement agreement providing for Defendant's partial custody periods, Defendant has exposed the child to certain harmful and dangerous situations, including but not limited to: a) driving with the child in the car after he has been drinking; b) taking the child to work with him when he sprays insecticides and other noxious agents around her; c) leaving her unattended in his car. 8. Each parent whose parental rights to the child have not been terminated have been Ilamed as parties to this action. WHBREPORE, Plaintiff requests that this Court grant her custody of Brandy Marie Bowman. L~ Theresa Barrett Male, Es Supreme Court # 46439 10 South Market sq. - Suite 500 Harrisburg, Pennsylvania 17101 (717) 233-3220 Attorney For Plaintiff Date: "?/7frJ- / f 3 II. CUSTODY AND VISITATION 2.1 Th. primary physical r.sidence of the minor child shall be with the Wife and the Husband ehall have rea.onabl. vi.itation with the child any time he i. in the Eff.rs, PA area upon giving seven days notics that he will do .0. Additionally, during the summer monthe of June, July and August 1990, he .hall have twenty on. day. viaitation where .ver he desire. but mu.t furni.h Wife thirty day. notice. All visitation shall b. at Hu.bands' exp.nse. For the year 1991 and th.re- after the summer vi.itation sh.ll incr.... to thirty d.y.. 2.3 soth p.rties .gree to keep the other reasonably in for m.d .s to any matter .ff.cting the best inter.st of the child. This would includ. serious illn..s( me.ning any illness which confines the child to bed for three d.ys'. 2.4 The custody and visitation arrangements shall contin- ue regardle.. of the remarriage of the parties. Each party shall notify th other of any change in address or telephone numb.r. I' [: !: H I , I, " Ii " I !: i I ; I i III. SUPPORT 3.1 Husband agrees to pay to the Wife for support of the minor child the .um of Two Hundred( $200.00) per month until the child r.aches h.r majority, becom.s s.lf .upporting, marri.. or di.s. 3.2 Th. child support payments shall be paid through the Clerk of the Circuit Court, H.rnando County, Florida and transmitt.d to Wife a. provided by law. 3.3 The Wife shall be able to claim the minor child ae a dependant in 1990 anu subsequont years for tax purposes. IV ALIMONY 4.1 Both Hu.band and Wife hereby forever waive any claim against the other, past, present and in the future. V. PERSONAL PROPERTY 5.1 Both parties .hall own all per.onal property each ha. in their pos.e..ion except for tho.e items stated in 5.2. 5.2 Upon .xecution of this Agr.em.nt by Wife the Husband .hall deliv.r to Wif..' broth.r a' clock from her grandmoth.r bl the picture from Wife'. deceased .i.ter and c) Wife's hope chest. VI. REAL PROPERTY 6.1 Wife agrees to convey to Husband all of her right, title and interest she might h.ve in and to LOT' 3, BLOCK R, LEISURE RETREATS, UNIT ONE, HERNANDO COUNTY, FLORIDA togeth.r with the Mobil. Hom. located thereon together with all furniture, furn- ishing. and fixture. contained therein. 6.2 As consideration for the Wife conveying her interest a. ..t forth in 6.1 Husband .h.ll pay to Wife One Thousand ($1000.00) Dollar. upon .xscution of this Agreement and Two Thousand ($2000.001 Dollar. when the property is sold or within four year., whichever occurs fir.t.. Husband .hall give to Wife a prom- i..ary not. for that amount but .hall be non interest bearing. Th~~ Quit Claim Deed .Rd tJni.lu" .....f P~t"ITRey reF t.~~ rrg~i.le n.:.ou'g L1Llaa W shall likewise be signed upon ~xecution of this ^9r~emont. 6.3 The Husband shall be ",ntit1.,d to cl.im .s his sole deduction for 1989 all interest. taxes or othel allow.ble expen.e.. Pdg", 2 VII. DEBTS 7.1 Husbsnd sgrees to assume and pay the outstanding debts of the parties as of the date of their separation in July, 1989. This includes Wifes' father, Husbands father and ECI Credit Union. VIII. GENERAL PROVISIONS 8.1 No modification or waiver of any of tha terms hereof shall be valid unless in writing and signed by both parties. a.2 This Agreement shall be construed as a Post Nuptial Agreement entered into by the parties after consultation with their respective attorneys and shall be incorporated and made a part of the Final Judgement of Dissolution to be entered in this cause. a.3 In the event it is necessary for either party to in- cur attorneys fees or costs to enforce this Agreement, then the prevailing party shall be entitled to recover same from the other party. 8.4 The parties agree to hold harmless each other for any loss the other occurs as a result of the breach or failure to perform the obligations under this Agreement. IN WITNESS WHEREOF the parties have set their hand and seal in triplicate on the year and day above written, each copy of which may be considered an Original. ~d?~J~ ~".,,""'- AMY ISTEN BOWMAN STATE OF PLORIDA COUNTY OP HERNANDO BEFORE ME, the undersigned authority, personally appeared WILLIAM ROGER BOWMAN, who after being first duly sworn, deposes and says that he has read the foregoing document a~freely and volun- tarily affixed his signature thereon this.;.t day of }1/"~' 1990. ~ ~ ~~ '/A://..I~Jr ~~/~ NOTARY PUBLI ~ ,/t:;L'~' ~,~~ WILLIAM ROGE OWMAN My commisirn Expires. I -.r." IWL.:C ITAn 01 norlDl ~~.. IU. 01;1. ',1" -- 1_ MIIUl III. ... I. . STATE OF PENNSYLVANIA COUNTY OF hn.u. Mt"": BEFORE ME, the undersigned authority, personally appeared AMY KRISTEN BOWMAN, who after being first duly sworn, depose8 and says that she has read the foregoing document and freely ;:~,~~~~ tarily affixed her signature thereto this ~~r~ day of ~, 1990. My Commission Expires, 1./11 t./,?" <"~ ,... j, ~; 11.~.a-I..u., NOTARY PUBLIC Page 3 . /'fAR _ 1 1995 ~r.J Theresa Barrett Male Supreme Court 146439 10 South Market Square Suite 500 Harrisburg, PA 17101 (717) 233-3220 Attorney For Plaintiff AMY K. KOKOS, plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.C(5-I032. civil Term 1995 : v. . . W. ROGER BOWMAN, Defendant . . . . . . CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this d"oI. day of ~'- , 1995, upon consider- ation of the attached complaint for Custody, it is reby di,rected that the, parties and their respective counsel appear before jO, Esquire, the Conciliator, at hotII' office, t. :1-..- on the ~:)f!' day of ,1995, 9:0/,> A m. for a pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute I or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds fer the entry of a temporary or permanent Order. For the Court, Date of Order. 3-.;J'~Y By. /5/ Lh...41 , 5~ .. ')/~".a:z.11' t'Ju.. Custody Conciliator / R.'fl' Jk L YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse - 4th Floor 1 courthouse Avenue Carlisle, PA 17013-3387 (717) 240-6200 . , -'->.---".,.- --- _.', ..._....~..- '. THERESA BARRE1T MALE COUN5ItLORATLAW 10soUTtlMARKETSQUARE SUITE 110O HARRISBURG,PA 11101 !' ,/1AR - 1 t99! )yiJ "',',"; ",-,i:';;'~' -~;;\;:;i~)Y4.:::~~~~fiN~:;"~~~~~""'<" '. r , ~ -- Amy L. Bowman (Kokos) Old Trail Road Etters, PA 1989 - 8/93 The mother of the child is Amy L. Kokos, currently residing at 112 Wyncote Court, Mechanicsburg, PA 17055. She is married. The father of the child is W. Roger Bowman, currently residing at 5960 89th Avenue North, Pinellas Park, Florida 34777. He is single. 4. The relationship of plaintiff to the child is that of The plaintiff currently resides with the following mother. persons: her husband, Dean Kokos, and the subject child. 5. The relationship of Defendant to the child is that of father. The Defendant currently resides with the following persons: his parents. 6. Plaintiff has participated as a party in litigation concerning the custody of the child in the parties' uncontested divorce action which was filed in the circuit Court, Fifth Judicial Circuit, in and for Hernando County, Florida and docketed to case number 89-1103-CA-01. A true and correct copy of the Final Judgment Dissolving Marriage, with the property settlement agreement, is attached as Exhibit "A". Plaintiff has no information of a custody proceeding concern- ing the child pending in a court of this Commonwealth. 2 L~ plaintiff does not know of any person not a party to this proceeding who has physical custody of the child or who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because, since the parties executed the settlement agreement providing for Defendant's partial custody periods, Defendant has exposed the child to certain harmful and dangerous situations, including but not limited to: a) driving with the child in the car after he has been drinking; b) taking the child to work with him when he sprays insecticides and other noxious agents around her; c) leaving her unattended in his car. 8. Each parent whose parental rights to the child have not been terminated have been named as parties to this action. WHBRBFORE, Plaintiff requests that this Court grant her custody of Brandy Marie Bowman. Theresa Barrett Male, Es Supreme Court # 46439 10 South Market sq. - Suite 500 Harrisburg, Pennsylvania 17101 (717) 233-3220 Attorney For Plaintiff Date: ~/7~J- / I 3 .I~ . (', , IN TH"'CIRCUIT COURT, FlnH JUOICIAL t;;.l;UlT. IH AND FOR HERNANDO COUHTY. FLORIDA IN All Thl aarria.. of WILLIM1 ROGER BOWMAN, HUlblnd Ind I I I I I I I I I I I I CASE NO. 89-110J-CA-Ol DIVISION' "B" AMY KRISTEN BOWMAN, WH.. FINAL JUDGHENT DISSOLVING HARlIAGE UNDER SIHlLIFIED DISSOLUTION PROCEDURE Thil .ction c... b.for. tho Court upon tho pltition of tho p.rtil. for di.lolution of thlir .arria.l. Upon conl1d.racion thlrlof. IT 15 ADJUDGED th.t tho bond. of ..rria.. bUllIOn tho Hu.band, WILLIAM ROGER BOWMAN, .nd tho Wife, AMY KRISTEN BOWMAN .r. dillolv.d. (If .pplic.bl.) IT IS FURTHER ADJUDGED th.t tho Wif.'. for..r n... il rl.torld .nd ,h. .hall h.r.aftlr bl known al NOT APPLICABLE (If .ppllc.bI.) IT IS FURTHER ADJUDGED th.t tho prop.rty I.ttl...nt ..r....nt fil.d in thh proceedln. a. Exhibit "A" va. Ixecuted voluntarily ahlr full dhclolure .nd i. .pprov.d .nd lncorpor.t.d in thi. judsment b. ref.r.nce, .nd th.tP.r~~,i .r. ordeJ'd to to.ply lIith it. /. '. ..". , .. ,:' Brooks1/111e, . , .. ,,;fll!',;';;,' .' ORDERED.t Hsrnando County. Florid., on thie 7TH HAY., ;..,... 'J)990. . ,,~,' '"',~ " ........,~ " " '.'':.~ 4, : . . . . . . ,'.f , ...1 : o . " j, ..~. " ." I, '....' t.) ~. ' ~ \," . .:; I :.' . I 1.( '.'"t J ,. o - c.n c.n c.n c.n 0.". 116 ,6 t3t3 ..:: tt) tii?:~" a ..:I.:)... ::tfll" ;.~~~:: ',J, 'I~' .. ", . 1,..:" '--r'l : ~;"Jn I ~: . .',oti 0 '" . ',.1 I :; SlAT! or norl~\ COUNIY Of 1:'0':""0 lhi1.~tocC'l"'~ I """1"""<<"" tr'I.... ~ t tl;",,!Il'" ",''!' ,tlll'l.,' tn,."., I' \',:,' Ill," ,,"," 'f.!J , I' ',. ,0 EXHIBIT I A 'I.... \' t I, I, I ! i I, I' II. CUSTODY AND VISITATION 2.1 The primary physical residence of the minor child shall be with the Wife and the Husband shall have reaaonable visitation with the child any time he is in the Effers, PA area upon giving seven days notice that he will do ao. Additionally, during the summer months of June, July and August 1990, he shall have twenty one days visitation where ever he desires but must furnish Wife thirty days notice. All visitation shall be at Husbands' expense. For the year 1991 and there- after the summer visitation shall increase to thirty days. 2.3 Both purtios agree to keep the other reasonably infor med as to any matter affecting the best interest of the child. This would include serious illness( meaning any illness which confines the child to bed for three daysl. 2.4 The custody and visitation arrangements shall contin- ue regardless of the remarriage of the parties. Each party shall notify th other of any change in address or telephone number. III. SUPPORT 3.1 Husband agrees to pay to the Wife for support of the minor child the sum of Two Hundred( $200.00) per month until the child reaches her majority, becomes self supporting, marries or dies. 3.2 The child support payments shall be paid through the Clerk of the Circuit Court, Hernando County, Florida and transmitted to Wife as provided by law. 3.3 The Wife shall be able to claim the minor child as a dependant in 1990 and subsequent years for tax purposes. IV ALIMONY 4.1 Both Husband and Wife hersby forever waive any claim against the other, past, present and in the future. V. PERSONAL PROPERTY 5.1 Both parties shall own all personal property each has in their possession except for those items stated in 5.2. 5.2 Upon execution of this Agreement by Wife the Husband shall deliver to Wifes' brother a) clock from her grandmother b) the picture from Wife's deceased sister and c) Wife's hope chest. VI. REAL PROPERTY 6.1 Wife agrees to convey to Husband all of her right, title and interest she might have in and to LOT' 3, BLOCK R, LEISURE RETREATS, UNIT ONE, HERNANDO COUNTY, FLORIDA together with the Mobile Home located thereon together with all furniture, furn- ishings and fixtures contained therein. 6.2 As consideration for the Wife conveying her interest as set forth in 6.1 Husband shall pay to Wife One Thousand ($1000.00) Dollars upon execution of this Agreement and Two Thousand ($2000.00) Dollars when the property is sold or within four years, whichever occurs first.. Husband shall give to Wife a prom- issary note for that amount but shall be non interest bearing. Th~~ Quit Claim Deed .Ad I)""i.'''''' "'f '''tgTRey fer Uua Rlgbi.l~ n......I.. LILlvD ItfJ shall hkcwisc be signed upon '>xecutlon of thl~ ^9r"enlent. 6.3 The Ilusbund shnLl he -:"ntit.-l~d t.o r:lalm laS his dole deduction for 1989 all Interest, taxes or other allowable expenses. Pdt... 2 VII. DEBTS 7.1 Hui6iiii1 agrees to ....ume ..nd p..y the outst..nding debts of the parties as of the date of their eeparation in July, 1989. This includes Wifes' father, Husbands father and ECI Credit Union. VIII. GENERAL PROVISIONS 8.1 No modification or waiver of any of the terms hereof shall be valid unlese in writing and signed by both parties. 8.2 This Agreement ehall be construed as a Post Nuptial Agreement entered into by the parties after consultation with their respective attorneya and shall be incorporated and made a part of the Final Judgement of Disaolution to be entered in thia cauae. 8.3 In the event it ia neceaaary for either party to in- cur attorneys feea or coats to enforce this Agreement, then the prevailing party shall be entitled to recover same from the other party. 8.4 The parties agree to hold hermless each other for any loss the other occurs as a reeult of the breach or failure to perform the obligations under this Agreement. IN WITNESS WHEREOF the parties have set their hand and seal in triplicate on the year and day above written, each copy of which may be considered an Original. /J PUJ~ ~U'~"1(... ~~ISTEN BOWMAN STATE OF FLORIDA COUNTY OF HEIUlANDO BEFORE ME, the undersigned authority, peraonally appeared WILLIAM ROGER BOWMAN, who after being first duly aworn, depose. and says that he has read the foregoing document a~freelY and volun- tarily affixed hia signature thereon this.;(' day of ~_.._--lt. 1990. ~{~<-- ~'d//.u..k~ ~J~./--<'J E.xpires' ~OTARY PUBLI~ --- -." fIWL:C ".." 01 tWill ~~lU.Olit.l.l. - 1- ...Illa._. .~.. , . - . -,: My COlDllliair I I. . STATE OF PENNSYLVANIA COUNTY OF bn-.u P--h....:.. BEFORE ME, the underaigned authority, personally appeared AMY KRISTEN BOWMAN, who after being first duly sworn, deposes and says that she has read the foregoing document and freely ;~~~~~~~ tarily affixed her signature thereto thia .7-.,r~ day of .~, 1990. My COlDlllusion Expirea, IJi/~.I?I.' ~N6TA~Y ;lJ~~1rn-6~/' Pa".. 3 VERIFICATION I, Amy K. Kokos, state upon personal knowledge or information and belief that the averments set forth in the foregoing document are true. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsifica- tion to authorities. Date:~\~\~ ~ ~ - f. '.' '-V ~'~<i' f;~';:",~,;~;, ~~''1\:~i~..II~iih~-:tr~~ fOli';iNtnQ 'u'iVie":jio(Iil",' tNI'CIrd to you. " ,., , ' ~~ j. ""~: eO. ~ -,l~_~r2~t:~~:;:-~':.~:~::~;~)1~:$f;{~~f&~~~j.f~,;.: i A~ ~~.IO tho ,_ .,tho~, ~on..... -.".- :':';9~~~.~~0~;~;~~~f~~{i'f:~:' ~;::, '~,:,,~~~,=",%":=:-,,:=~_, :i'2.J].R~,'.'.',tilcted l)81iy.rY....&~;~,'I, i.'., . .::t....~:.\':-.,-~.>' - - - .,,', ,,'- ",' c.' Conaulttmlst,rfor f.,. "~.'~"i 7 3ii~!IlcIeAddreued t'lL ... ,., . 4a,Artlcl. Number..:>"...,: .!1:.~;,;d "tjt.#,f;B~wmJl~r ~;, 'Z 070 025354'I"!Tfl~ 9..6,O...,~..,~,9t, h Alenue.l!(orth 4b,.S.rvlceTyp....!...'"l.'{y.1 i ~riel1as Park FL -347.77 0 RIlII"~red,D 'n.ured'.A~;;i'1:'<~ 'll',~":\~,,~: . l[]c.rtllI.,hDcoo..' . 'lit.!; ,(i;;i'i( 0 Expm. M~II' 0 R.tum RlcilIpt fcif~!L~ ~i~~G:!:jt; .' 7. '0". Of,D.llvery ::,':JJ .... ... '-:;'::11\ !';\",..~'i ..COnlv "'~~,J!. . -'. - 't':'-'~%~~-J 8. H n Jt it H '..u.LCIPOll_71. II H! !llll;/l DOMESl1C RETU.RN RECE!Jtti:1i', _ '. ',' " :.',:_,.~':'i,';;.:~~~;;1~i~ BXHIBIT "A" THIEIUESA BARRI:1T MALlE COUNSELOR AT LAW 10lOUTH MARKETSQUARIt SUITE ISOO HARR_URCI,PA 17101 Theresa Barrett Kale Supreme Court #46439 10 South Market square Suite 500 Harrisburg, PA 17101 (717) 233-3220 Attorney For plaintiff AMY K. KOKOS, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-1032 Civil Term v. . . . . . . W. ROGER BOWMAN Defendant . . CIVIL ACTION - CUSTODY PRABCIPB TO THE PRO'l'HONOTARY: Please reinstate the complaint in the above-captioned matter. L4Mff~ Theresa Barrett Male, Esquire Supreme Court # 46439 10 South Market sq., suite 500 Harrisburg, Pennsylvania 17101 (717) 233-3220 Attorney For Plaintiff Date: 4/11/95 0- - ,-- " ,." ...... 0 '<", , <," ",' 'i.:::',;:\A';,. ^ - -:W:~-t~)~;;:ij~S;_,->::.-:: ;,'~.-( ;. I j , ~ . ;' r:; -", _,-'~"-i';"';' \:2J '" ,..,~ ... ..... '"' .-., , _~, .J.~ .~. . .~. ~r,' . :z:1;" ~'~~,~ 1."-" _.j ;;:' ).. ....". -<--- - ~ - ~ & .., ~ - tft . , THERESA BARRE;" MALE COUNSELOR AT LAw '. 10 SOUTH MAR~ SQUARE . SUITE 500 HARRISBURG, PENNSVLVANIA 17101 (717) 233-3220 FAX (717) 233-6862 April 13, 1995 W. Roger Bowman 5960 89th Avenue North Pinellas Park, FL 34777 Re: Kokos v. Bowman Dear Mr. Bowman: Enclosed is 'a certified copy of the reinstated complaint for custody in connection with the above-referenced matter. Sincerely, ISCA Enclosure cc: Amy K. Kokos EXHIBIT J ^ ",0 c-., ~n:1: ., r.,cr:.-!.- ;;.....,.,i ~t.~~~' ' I"..... ;;C;;;:1:f~ J:.:?::::; .'.;(:.';")0 :i: ~'.. ,.,.., ..,'" ."'(~ .~ ..... ;: .' . - ...... c..J .... en :i1 l~ 'c.:.m f:j~ ~~ ~~I ~ ell ~ ~~~ ~~ "='1 :!l ~61 AJ ~ .a ' g!:: '<ol -t ;1i5..!.~~ '<ol ,"' . !It, .. .- , ~~N AJ ~ i! . ,,, ~ - .~ iOI,tIi " ::l = o l"l !~ ~ 'S'--g ~~~ ! ~ ,0._ !~ :.... ::: ;; :-:: cr: en..c liil u"'.l1 ~ ' "" ~ ~ . lot: ~~ ~ . ~ . .' . - .. . - . - .. . . ~ AMY K. KOKOS, Plaintiff : IN THE COURT OF ca-IMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 95-1032 CIVIL TERM . . W. ROGER ~, Defendant . . : CUSTODY aIDER Of!' 00llR'l' '" . AND !1M, this 'Z I day of A~.. I consideration of the attached CUstody Conciliation ordered and directed as follows: , 1995, upon Report, it is hereby 1. The Mother, Amy K. Kokos, shall have primary physical custody of Brandy Marie Bowman, born SepterriJer 17, 1987. 2. The Father shall have reasonable partial custody of the Child any time he is in the Mechanicsburg, Pennsylvania area upon giving seven (7) days advance notice to the Mother. 3. The Father shall also enjoy partial physical custody of the Child for thirty (30) days each year during the sumner school vacation. The Father shall provide thirty (30) days advance notice to the Mother of the dates for sumner partial custody. The Father shall be responsible for transportation expenses related to his periods of partial physical custody. 4. Neither party shall drive with the Child while under the influence of alcohol. The Father shall not have the Child accompany him in the course of his employment as long as his employment involves the use of pesticides or other chemicals. 5. The Child shall reside with the Father or the Father's parents during periods of sumner partial custody. 6. If the Father is unable to care for the Child for any period during his sumner partial custody, the Father shall arrange for the Child's care by family merriJers with whom the Child is familiar. 7. The custodial parent shall promptly notify the noncustodial parent of any matters significantly affecting the best interest of the Child, including but not limited to, serious illnesses or conditions requiring emergency or special medical treatment. BY THE COURT, cc: W. Roger Bowman Theresa A. Barrett Male, Esquire e.. ~"'-.., ~ 'f/:J.'I/?r. ".8, -p, , /l lei J. APR Zlj 8 10 ~H '95 'i: fief Uf "h' 'H0t;','Af.~ Clli-~i:.:' .:'!1'~-i (>\, .try .'t ~j h:, ~ 'J ;', 'i 't. . . "! AMY K. KOKOS, Plaintiff/Respondent IN THE COURT OF COMMOO PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW W. ROGER BCMMAN, Defendant/Petitioner NO. 95-1032 CIVIL TERM CUSTODY aJSTCDY CDlCILIATION SlI1MARY RBPOOT IN ACCClUll\NCB wrm CDmERLAND CXllBl'lC RULE OF CIVIL PR):I<I ~ 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information pertaining to the Child who is the subject of this litigation is as follows: NAME BIRTHDATE CURRENTLY IN CUSTODY OF Mother/Plaintiff Branaj Marie Bowman September 17, 1987 2. A Conciliation Conference was held on April 12, 1995, with the Mother, Amy k. Kokos and her counsel, Theresa Barrett Male, Esquire present in the Conciliator's office. The Father, W. Roger Bowman, lives in Florida and participated in the Conference by telephone (speaker phone). Mr. Bowman was not represented by legal counsel at the time of the conference. 3. At the time of their Divorce, the parties entered into a written agreement concerning custody of the Child which was incorporated into a Court Order on May 7, 1990 by the Circuit Court of Hernando County, Florida (copy attached). The Agreement provides that the Mother shall have primary physical custody of the Child and the Father shall have reasonable visitation at any time in Pennsylvania upon notice and additionally during the sunrner months at the Father's residence for a period of thirty (30) days. 4. The Mother's position on CUstody is as follows: The Mother stated that she filed the Petition For custody to confirm the award of primary physical custody entered by the Florida Court. In addition, the Mother expressed concern about the Child's safety when she is in the Father's custody. Specifically, the Mother believes that the Child may have been exposed to pesticides when she allegedly accompanied her Father during the course of his employment as an exterminator. The Mother was also concerned that the Child llIay have been driving with the Father after the Father had been drinking alcoholic beverages. The Mother stated that her concerns arose from information obtained from the Child after the Child's last visit to her Father's residence in Florida. The Child was six years old at that time. The Mother requested restrictions on the Father's partial physical custody with regard to the safety issues and also a reduction in the period of sunrner partial custody from thirty (30) days to twenty-one (21) days. The request for a shortened period of partial custody was based on the Mother I s concern that the Child has become homesick in the past after '. - - _._-- ..-- .' -;.. . '"...- ~. ~ . .-." ,